Tuesday, September 12, 2023 5:28:41 PM
"The REITS themselves, however, were not members of the [WMI] Consolidated Tax Group and were not included in the consolidated federal returns. During the same period, WMI filed consolidated returns on behalf of the Consolidated Tax Group in Oregon as well. The REITS were not included in the consolidated Oregon returns. Thus, the income of the REITS from the REIT loans was not reflected in the consolidated federal or Oregon tax returns."
Background: same doc, page 1 "In late 1999, each of the REITS became directly-owned subsidiaries of a holding company of WMI and changed their
commercial domiciles from the State of Washington to Oregon."
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